Wednesday, May 12, 2010

Comments made to Access Board on May 12, 2010

On May 12, the United States Access Board held a public hearing on "its proposed refresh of requirements for information and communication technologies (ICT) covered by Section 508 of the Rehabilitation Act and Section 255 of the Telecommunications Act." I spoke at this hearing on some of the accessibility needs of hard of hearing people which did not appear to have been adequately addressed. As we had only three to five minutes to speak, my comments were streamlined. The gist of them is provided below. Sentences that are italicized below were not spoken out loud.


My name is Dana Mulvany, and I'm speaking here today as a consumer advocate who is hard of hearing; I also work as a consultant specializing in hearing loss issues. My comments today are focused primarily on the needs of people who are hard of hearing, of which there are more than 30 million in the U.S.A.

What I'll be doing here this morning is providing some information about the needs of people with hearing loss along with numbered technical points that I would like the Access Board to take into consideration.
  • A. Most hard of hearing people have much stronger hearing in the low frequencies compared to their ability to hear high frequencies. Many hard of hearing people cannot hear high frequency sounds at all.

  • 1. This means that alerting sounds for the general public should be required to contain multiple frequencies, especially low frequency sounds, and should not use just high frequency sounds.

  • 2. There needs to be a required option to customize alerting sounds for the need of the individual user with respect to the frequencies used by the alerting sound, not just the loudness level. (This will also help people with normal hearing in environments with substantial noise because due to the phenomenon of "upward spread of masking," low frequency sounds mask, or cover up, high frequency sounds.)

  • B. In order to decipher speech at their highest level possible, many hard of hearing people need high fidelity reproduction of speech across all speech frequencies with as little noise as possible.

  • 3. This means that all audio components need to be capable of high fidelity reception, transmission and generation of speech for maximum speech comprehension. These include microphones and telephone hardware used by people who do not have a disability themselves but who would communicate with hard of hearing employees and/or members of the public.

  • 4. Telephone and VoIP services also need to transmit high fidelity audio to the maximum extent possible. (Unfortunately, many cell phone carriers are choosing not to transmit the lower frequency part of the speech spectrum in order to conserve bandwidth, and this is having a highly adverse effect on the speech comprehension of hard of hearing people.) I thus endorse the Access Board's effort to address Audio Clarity for Interconnected VoIP.

  • 5. It would indeed be very helpful if the Board would require that any auditory features, where provided, include at least one mode of operation that improves clarity, reduces background noise, or allows control of volume, in addition to adding the other features I mention today. (This is my answer to Question 13.)

  • C. Because of uneven hearing loss in both ears, including single-sided deafness, many hard of hearing people need all the audio delivered either to one ear or both ears. In other words,

  • 6. Manufacturers need to provide an option to switch stereo sound to mono. (Apple has already been doing this for certain models of the iPod Touch and the iPhone 3GS.)

  • 7. It is often important to be able to use both ears to hear, not just one ear, because each ear may hear very differently. Whenever possible, the ability to hear with both ears should be provided.

  • D. Speech comprehension for hard of hearing people can increase enormously by being able to speechread and hear at the same time. For many people with severe hearing loss, speechreading provides information about consonants that they might not otherwise hear.

  • 8. Video communication technology therefore needs to support the simultaneous transmission of speechreading and audio at the same time for hard of hearing people. The technology should also support the provision of text from relay services directly on the video.

  • E. The majority of people with hearing loss do not use hearing aids.

  • 9. It would be highly desirable for communication equipment to provide customization of the frequencies in the audio signal. Apple has done this for music by providing an equalizer function on some of their iPhones and iPods. It would thus appear to be technically feasible for manufacturers to provide the same function for all audio emanating from their products.

  • F. Captioning is very important to people with significant hearing loss. Unfortunately, many people have significant trouble figuring out how to turn it on and may not even realize it is available.

  • 10. Controls for turning on and customizing captioning need to be as easy to use as possible.

Thank you for your attention to these important issues.

(End of written comments)


I plan to provide more complete comments, which are due to the Access Board by June 21st, 2010, and encourage other people to do so as well. Here are some of the related documents from the Access Board:



Feel free to provide some feedback or questions here about what I myself said.

[Note:  The due date for comments was corrected from June 12th to June 21st.] 


4 comments:

Jim said...

Thanks, Dana. I think all your points are valid. I would encourage your readers to consider sending in comments to the Access Board. When doing so, keep in mind that answers to their 33 specific questions and suggestions for specific improvements to the provisions (corrections, additions, etc.) are going to be easier for them to process.

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